A federal appeals court on this day ruled that City College in New York City violated the First Amendment and due process rights of philosophy professor Michael Levin who had written letters and articles, outside of the classroom, that on average African-Americans are less intelligent than whites. Students had disrupted his classes to protest his views, and the university created separate sections of the courses he taught for students offended by his views.

The court ruled that the university’s actions constituted a “chilling effect on free speech that violates the First Amendment.”

The controversy over Professor Levin coincided with separate one over Professor Leonard Jeffries who espoused theories of African-American superiority. The university removed Professor Jeffries as the chairperson of the Black Studies Department. Three days before the court decision in the Levin case, Jeffries filed a $25 million suit against the university for violating his rights.

Learn more: Samuel Walker, Hate Speech: A History of an American Controversy (1994)